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Final Installment of 2024 MCP Amendments Q&A

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on August 11, 2025: 

The final installment of the 2024 MCP Amendments Q&A has been posted as of August 11, 2025.

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WSC – CAM – VIII B, Analysis of Perchlorate Update

The LSPA received the following email from MassDEP Bureau of Waste Site Cleanup on August 1, 2025: 

Updated Compendium of Analytical Methods (CAM) protocols for Perchlorate, WSC – CAM – VIII B, Analysis of Perchlorate by Ion Chromatography (IC) with Electrospray Ionization/Mass Spectrometry (ESI/MS or ESI/MS/MS) or High Performance Liquid Chromatography (HPLC) with ESI-MS or ESI-MS/MS, have been posted to MassDEP’s web site at https://www.mass.gov/info-details/compendium-of-analytical-methods-cam#high-performance-liquid-chromatography-hplc-and-ion-chromatography-methods

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Recent Policy & Legislative Action from the LSPA

Dear LSPA Member,

As the voice of LSPs and environmental practitioners across Massachusetts, the LSPA is actively advocating to strengthen our profession and advance sound environmental policies. Below is a summary of what we’ve been working on recently:

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Happy New Year from the LSPA

2024 flew by while the LSPA advocated for the waste site cleanup practice and supported practitioners throughout the Commonwealth. We are always eager to review and assess our annual accomplishments and this year is no different. We can’t say “thank you” enough to LSPA members, committees, workgroup leaders, and committee chairs who make this association successful. We also applaud our annual and event sponsors who underwrite our work; we appreciate your confidence in our ability to carry out our mission. Below are some 2024 highlights.  

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LSPA Introduces Compliance Tip of the Month for December 2024

The following LSPA compliance tip was introduced at the December 2024 Membership Meeting, which was held via Zoom on December 18, 2024.

Compliance Tip of the Month
While the MCP requires an assessment of “reasonably foreseeable future changes in site conditions” related to climate change, it does not indicate a specific assessment timeframe. 

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Deadline Extended; Still Soliciting Comments on Two Draft MCP Guidance Documents

MassDEP’s deadlines for written comments have been extended to June 5, 2024 for both guidance documents currently posted on the MCP Amendments web pageRisk Characterization Guidance, Chapters 1-5, Public Review Draft” and Interim Guidance on Implementing Activity and Use Limitations.

The two LSPA groups reviewing these guidance documents are still looking for comments. If you want to join the review group or have comments you wish to share on the Risk Characterization Guidance, please contact [email protected] by no later than May 9th. 

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MassDEP BWSC Advisory Committee Meeting Highlights

A MassDEP BWSC Advisory Committee meeting was held on February 15, 2024. This webpage has slides and video from the meeting. Some highlights are below.

In this video, Brian Roden, BWSC Audits and Enforcement Coordinator, provides a summary of the 2024 MCP Amendments for AEPMMs addressing Vapor Intrusion.

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New MCP 2024 Amendment Topics

In anticipation of March 1, 2024, when the MCP Amendments go into effect, the LSPA’s Regulations Committee has been working on summarizing key changes to the MCP regulations. 

Provided below is a summary of the new regulations on a variety of topics not covered by previous LSPA email blasts. This information was developed and is provided on behalf of the LSPA only; it does not represent MassDEP guidance or other input. 

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MCP 2024 Amendments Impact on Climate Change

In 2020, the LSPA formed a Climate Change Subcommittee (of the Technical Practices Committee) to consider how waste site cleanup practitioners might address anticipated MCP amendments on that topic. In 2022, the subcommittee produced and shared a Climate Change Toolkit. Now, the MCP Amendments are final and it’s time to start using the toolkit! 

The new MCP includes climate change-related language in specific sections on these topics: 

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The New MCP on Sampling and Exposure Points

In anticipation of March 1, 2024, when the MCP Amendments go into effect, the LSPA’s Regulations Committee has been working on summarizing key changes to the MCP regulations. 

The links below provide summaries of the three Sampling and Exposure Point Concentration topics that have materially changed from the 2019 regulations:

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MCP Amendments Information Webpage and Method 3 Shortform Corrections

The LSPA received the following email from MassDEP's Bureau of Waste Site Cleanup on Friday. 

Dear Waste Site Cleanup Program stakeholder,

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LSPA Introduces Compliance Tip of the Month for December 2023

The following LSPA compliance tip was introduced at the December 2023 Membership Meeting, which was held remotely on December 12, 2023 via Zoom.  

Compliance Tip of the Month

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The New MCP on Three Topics

In anticipation of March 1, 2024, when the MCP Amendments go into effect, the LSPA’s Regulations Committee has been working on summarizing key changes to the new regulations. 

Provided below is a brief summary of the new regulations on the topics of

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LSPA Introduces Compliance Tip of the Month for November 2023

The following LSPA compliance tip was introduced at the November 2023 Membership Meeting, which was held remotely on November 15, 2023 via Zoom.  

Compliance Tip of the Month

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MassDEP Slides and Recording from LSPA's September Member Meeting

The LSPA was pleased to have Acting Assistant Bureau of Waste Site Cleanup (BWSC) Commissioner Elizabeth Callahan and Acting Director of BWSC’s Policy and Program Development Division Ken Marra speak at our September 21, 2023 meeting at the Newton Marriott. 

This event, always very popular, was attended by nearly 200 guests this year – we expect because of the highly-anticipated, recent promulgation of the 2024 MCP Amendments.

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Top Takeaways From 2019 Proposed Amendments to the MCP

MassDEP leadership has recently shared that they expect the next set of Amendments to the Massachusetts Contingency Plan (MCP), proposed in 2019, to be promulgated soon. In an effort to refresh our collective memories, the LSPA Regulations Committee has prepared this brief, high-level summary of eight key aspects of the proposed MCP regulations. The summary provided below is based on the draft revisions provided in 2019. The LSPA has not seen a more recent draft. The actual contents of the forthcoming MCP revisions are not known.

Hot Spot and MGP Waste Definitions 
The 2019 proposed amendments include the addition of Manufactured Gas Plant (MGP) Waste as a defined term. Additionally, the amendments propose modifying the definition of a hot spot to include areas of waste disposal including MGP waste. These proposed changes effectively create a new class of oil and hazardous material (OHM), with concomitant requirements for sampling and risk assessment.

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LSPA Introduces November 2022 Practice Tip of the Month

The following LSPA practice tip was presented at the November 2022 Membership Meeting, which was held virtually through the Zoom webinar platform, on November 15, 2022.  

Practice Tip of the Month: 
The LSPA has developed a Climate Change MCP Toolkit to assist practitioners as they consider the potential effects of climate change on site assessment and response actions. This is anticipated to be required by the pending amendments to the MCP.  The toolkit includes a flowchart, checklist, two case studies, glossary, and list of resources.

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Notes from BWSC Advisory Committee, and Comment Period on MA Climate Change Assessment Report

Notes from BWSC Advisory Committee

MassDEP’s Bureau of Waste Site Cleanup Advisory Committee met on October 27, 2022 for several hours. Typically, MassDEP posts the slides and recordings of Advisory Committee meetings here. At this time, these have not yet been posted.

A brief summary of meeting highlights is provided below.

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LSPA Climate Change MCP Toolkit Available

The LSPA has developed a Climate Change MCP Toolkit to assist waste site cleanup practitioners as they consider the potential effects of climate change on site assessment and response actions. This is anticipated to be required by the pending amendments to the Massachusetts Contingency Plan (MCP).  

The climate change toolkit is available through links in this email as well as on the LSPA website. The tools are reflective of the framework defined in the (the SHMCAP, MA SHMCAP Portal). The SHMCAP accounts for projected changes in precipitation and temperature, sea level rise, and extreme weather events, and aims to reduce the risks associated with natural hazards and the effects of climate change.

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MassDEP’s June 2021 Waste Site Cleanup Advisory Committee Meeting

MassDEP’s Bureau of Waste Site Cleanup (BWSC) Advisory Committee meeting was held on June 24, 2021. The meeting covered several timely items; the meeting recording can be found here under June 24, 2021 Discussion Items and the meeting slides are here.

Topics covered included:
  • Regional Personnel Updates  
  • MCP Amendments
    • Internal MassDEP approvals expected to be completed this summer with final regulations published in the fall
    • Training for LSP credit, and Q & As specific to the amendments to follow
    • MassDEP also expects to finalize guidance documents related to final amendments including risk characterization
  • Subscribe to MassDEP Notifications 
  • Compendium of Analytical Methods (CAM) Update
    • Revised CAM protocols for 8260 (Volatile Organic Compounds) and 8270 (Semivolatiles)
    • Revised protocols posted on July 22, 2021 and take effect November 5, 2021 
  • Technical Assistance Grants and MOSPRA Grant Program Premier  
  • Assessing Climate Vulnerability at 21E Sites 
  • PFAS in Massachusetts
    • An excellent comprehensive review of the status of PFAS related efforts over the years and currently underway, including links to databases on MassDEP website
  • Office Hours and WSCAC Meetings
    • MassDEP plans to continue holding virtual meetings - Thursday morning “office hours” and Thursday morning WSCAC meetings both on the 4th Thursday of the month.  
    • Next Advisory Committee meeting is Thursday, September 23, 2021 at 9:00 am